Hamlin Dev. Co. v. Commissioner
United States Tax Court
P, a corporation, established a pension plan in 1980. In 1983, petitioner received a favorable determination letter from respondent stating that P's pension plan was a qualified plan under sec. 401(a), I.R.C.
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P, a corporation, established a pension plan in 1980. In 1983, petitioner received a favorable determination letter from respondent stating that P's pension plan was a qualified plan under sec. 401(a), I.R.C. The letter also stated that respondent's determination was effective for plan years beginning after March 31, 1981. In 1990, respondent mailed petitioner a final revocation letter stating that the favorable determination letter was retroactively revoked for plan years ending on or after March 31, 1985. Respondent's given reason for this revocation was that, although petitioner allegedly…
1Opinion of the Court
HAMLIN DEVELOPMENT COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hamlin Dev. Co. v. Commissioner
Docket No. 8324-90R
United States Tax Court
T.C. Memo 1993-89; 1993 Tax Ct. Memo LEXIS 94; 65 T.C.M. (CCH) 2071;
March 15, 1993, Filed
P, a corporation, established a pension plan in 1980. In 1983, petitioner received a favorable determination letter from respondent stating that P's pension plan was a qualified plan under sec. 401(a), I.R.C. The letter also stated that respondent's determination was effective for plan years beginning after March 31, 1981. In 1990, respondent mailed…
2Cases cited19 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Aero Rental v. CommissionerUnited States Tax Court · 1975
- B.H.W. Anesthesia Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Carstenson v. CommissionerUnited States Tax Court · 1972
- Buzzetta Constr. Corp. v. CommissionerUnited States Tax Court · 1989
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